giuffre-maxwell
gov.uscourts.nysd.447706.1200.17
5 pg
… She was a
25 little reluctant initially, but because of the
Page 107
1 JOSEPH RECAREY - CONFIDENTIAL
2 fact that it was his money that purchased the
3 items, she showed the outfit that she had
4 purchased at…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.22
5 pg
…of the
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-22 Filed 01/05/24 Page 4 of 5
Page 107
1 JOSEPH RECAREY - CONFIDENTIAL
2 fact that it was his money that purchased the
3 items…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…in defendant’s possession.
Setting aside that this is not what the RFP asked for, that too would entail an
extraordinary and unreasonable amount of time and money, since plaintiff’s
various names are guaranteed to have thousands of hits…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…an an-esting column item as a favor to her- if indeed the item is applicable for Page Six? But it must have true
gravitas.
No money changes hands in such a news release to a publication! If it helps…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…Richards.
4. All Docume nts containing communications with
law enforcement agency concerning Virginia
Roberts.
5. All Documents reflecting any payment of any
money to Virginia Roberts.
6. All Documents reflecting any contract
…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…her younger sister, then only 16. He’d gotten to them because of
his money. He promised the older sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…in defendant’s possession.
Setting aside that this is not what the RFP asked for, that too would entail an
extraordinary and unreasonable amount of time and money, since plaintiff’s
various names are guaranteed to have thousands of hits…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
6. “Including” means including without limitations.
7. “Income” includes income in-kind, and means all money, stock, bonds, in-kind
income, earnings, salary, pay…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…Giuffre’s counsel, and her offer to take the deposition at a
place and date convenient for Mr. Gow.
Ms. Giuffre has expended considerable time and money in an effort to serve process upon
Mr. Gow. Ms. Giuffre served process…
giuffre-maxwell
1320-3
6 pg
…I believe that I have read that ,
9 but I don 1 t have any memory of it.
10 Q. Did you ever tell Johanna that she
11 would get extra money if she provided Jeffrey
12 massages?
13 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.3
6 pg
…I believe that I have read that ,
9 but I don 1 t have any memory of it.
10 Q. Did you ever tell Johanna that she
11 would get extra money if she provided Jeffrey
12 massages?
13 A…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…her younger sister, then only 16. He’d gotten to them because of
his money. He promised the older sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.4_2
6 pg
…8 A. I believe that I have read that,
9 but I don't have any memory of it.
10 Q. Did you ever tell - that she
11 would get extra money if she provided Jeffrey
12 massages?
13 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.199.0
8 pg
…Personal
Service.) Mr. Epstein refused to accept service, thereby forcing Ms. Giuffre to hire investigators
and spend considerable time and money in an attempt to personally serve the Defendant’s former
boyfriend, employer, and co-conspirator, with whom she has…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…A Mr Chan and a Mr Cooper, solicitors on the Isle of Man,
devised a scheme involving moneys being held off-shore and in trust. In the course of
devising the scheme a document known in these proceedings as a…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…to the
press, as if it was a diary, when it was just a story that she is writing of fiction,
fictional story for money.
Q. How did you arrive at the words that were put in that statement?
MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…fees, if you know?
16 A. I have a pro-bono
17 arrangement.
18 Q. Do you know if he's
19 receiving money from anyone else in
20 exchange for representing you?
21 A. No.
22 Q. No, you…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…purpose.
Without waiting such objections, Ransome is not in possession of any documents
responsive to this request.
13
15. All Documents reflecting any money, payment, valuable consideration or other remuneration
received by You from Jeffrey Epstein or any person known…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…objections, Ransome is not in possession of any documents
responsive to this request.
13
Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 15 of 27
15. All Documents reflecting any money, payment, valuable…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…stub, earnings statement and any bank
statement, credit card statement and any Document reflecting any money owed by You to
anyone.
7
The remaining document requests are specifically targeted to obtain impeachment
evidence concerning Ms. Ransome’s story, as…
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